Free Motion to Dismiss - District Court of Delaware - Delaware

Case 1:05-cr-00052-JJF Document 9 Filed 06/21/2005 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. THOMAS L. WILLIAMS, Defendant. ) ) ) ) ) ) ) ) )

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Criminal Action No. 05-52-JJF

MOTION AND ORDER TO DISMISS NOW COMES the United States of America, by and through its attorneys, Colm F. Connolly, United States Attorney for the District of Delaware, and Ferris W. Wharton, Assistant United States Attorney for the District of Delaware, and hereby moves this Honorable Court to dismiss Count I the Indictment. In support thereof the government represents that the defendant has pled guilty in the Superior Court of the State of Delaware to charges arising out of the same incident as Count I, for which he received a three year minimum mandatory term of imprisonment. The government believes that such term of imprisonment adequately punishes the conduct which gave rise to this Indictment.

COLM F. CONNOLLY United States Attorney

By: /s/ Ferris W. Wharton Ferris W. Wharton (ID # 945) Assistant United States Attorney Dated: June 21, 2005

SO ORDERED this ________ day of ______________________, 2005.

_______________________________________ Joseph J. Farnan United States District Judge

Case 1:05-cr-00052-JJF Document 9 Filed 06/21/2005 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. THOMAS L. WILLIAMS, Defendant.

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) ) ) ) ) Criminal Action No. 05-52-JJF ) ) ) )

CERTIFICATE OF SERVICE I, Jennifer Brown, an employee in the Office of the United States Attorney, hereby certify under penalty of perjury that on June 21, 2005, I electronically filed: Motion and Order to Dismiss with the Clerk of Court using CM/ECF. Said document is available for viewing and downloading from CM/ECF, which will send notification of such filing(s) to the following: Penny Marshall, Esquire Federal Public Defender District of Delaware 704 King Street, Suite 110 Wilmington, DE 19801

/s/ Jennifer Brown